BEFORE THE DEPARTMENT OF TRANSPORTATION WASHINGTON, D.C.

_________________________________________ ) Application of ) ) ORANGE AIR, LLC ) DOCKET DOT-OST-2011- ) for a Certificate of Public Convenience ) and Necessity (Foreign Passenger ) Charter Service) ) _________________________________________ ) APPLICATION OF ORANGE AIR, LLC FOR A CERTIFICATE OF PUBLIC CONVENIENCE AND NECESSITY Communications with respect to this document should be sent to:

John R. Mietus, Jr. Law Office of John Mietus, LLC 6701 Democracy Blvd., Suite 300 Bethesda, MD 20817-7500 (202) 747-5212 - Telephone (240) 396-5362 - Fax john@mietuslaw.com Counsel for ORANGE AIR, LLC APPLICANT REQUESTS THAT THIS APPLICATION BE PROCESSED THROUGH EXPEDITED, NON-HEARING PROCEDURES PURSUANT TO SUBPART B OF THE DEPARTMENT’S PROCEDURAL REGULATIONS. NOTICE: Any person may support or oppose this application by filing an answer no later than April 22, 2011 an d serving a copy of the answer on counsel for Applicant and upon persons served with this application. April 1, 2011BEFORE THE DEPARTMENT OF TRANSPORTATION WASHINGTON, D.C.

_________________________________________ ) Application of ) ) ORANGE AIR, LLC ) DOCKET DOT-OST-2011- ) April 1, 2011 for a Certificate of Public Convenience ) and Necessity (Foreign Passenger ) Charter Service) ) _________________________________________ ) APPLICATION OF ORANGE AIR, LLC FOR A CERTIFICATE OF PUBLIC CONVENIENCE AND NECESSITY Pursuant to 49 U.S.C. § 41102 and subpart B of the Department’s Procedural Regulations, Orange Air, LLC ("Orange Air") respectfully applies for a certificate of public convenience and necessity authorizing Orange Air to engage in foreign charter air transportation of persons, property, and mail between any place in the United Stat es and any place outside thereof. As Orange Air wishes to begin passenger operations in both domestic and foreign markets late in 2011, it reques ts that the Department process thisapplication expeditiously, using written submissions and simplified, nonhearing procedures as contemplated by sections 302.207 and 302.210(a)(2) of the Procedural Regulations, and proceed directly to a final order granting theOrange Air Foreign Certificate Application Page 2 requested certificate. 1 In support of this Application, Orange Air states as

follows:

1. Simultaneously with this Application, Orange Air has applied for a certificate authorizing it to engage in interstate charter air transportation of persons, property, and mail. Orange Air has provided detailed citizenship and fitness information in that Application and its Exhibits and Confidential Exhibits, and pursuant to 14 C.F.R. § 204.3, Orange Air hereby incorporates that material by reference in this Application.

2. As discussed in detail in the companion application, Orange Air is a

U.S. citizen and has the financial stre ngth to insure its ability to operate passenger charters, and its senior ma nagement has the necessary business expertise and technical ability to operate international passenger flights.

3. Orange Air wishes to make MD -80 series aircraft service available to charterers either in foreign or domest ic U.S. markets. While this flexibility requires additional economic auth ority from the Department, foreign operations of the same type and with the same aircraft will not require any

1 / Orange Air recognizes that the final order will undergo Presidential review under 49 U.S.C. § 41307, and it asks that the Department facilitate the prompt completion of that review.Orange Air Foreign Certificate Application Page 3 material changes to Orange Air's business systems, finances, or management. 2

4. The foreign charter air tran sportation Orange Air proposes is consistent with the public convenience and necessity as required by 49 U.S.C. § 41102(b)(2). The Department continues to recognize the Civil Aeronautics Board’s finding in Order 78-7-106, The Former Large Irregular Air Service Investigation , that there is a continuing demand and need for additional charter air carriers. See, e.g., Atlas Air, Inc. , Order 2010-5-24, at 1 n.1. Moreover, grant of the requested certificat e authority is in the public interest, as it will allow Orange Air to offer charterers new price and service options for international passenger transportation.

2 / Nor will substitution of foreign service fo r forecast domestic service cause any change in its net fuel consumption, and Orange Air has determined that adequate fuel is available for this service. To the extent the Department nonetheless concludes that grant of the requested authority would constitute a major regulatory action, Orange Air requests that the Department waive the requirement that an Energy Statement under 14 C.F.R. Part 313 be prepared.